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RULE PROPOSALS Proposed Amendments: N.J.A.C. 13:44C-3.2, 3.4, and 3.5 Proposed Repeal: N.J.A.C. 13:44C-3.3 Requirements for Licensure; Additional Education Requirements; Licensure without Examination due to Licensure in Another State; Requirements for Clinical Internship Authorized By: Eric T. Kanefsky, Acting Director, Division of Consumer Affairs. Authority: N.J.S.A. 45:3B-24. Calendar Reference: See Summary below for explanation of exception to calendar requirement. Proposal Number: PRN 2012-094. Submit written comments by September 14, 2012 to: Renee Clark, Executive Director Audiology and Speech-Language Pathology Advisory Committee Division of Consumer Affairs 124 Halsey Street PO Box 45002 Newark, New Jersey 07101 The agency proposal follows: Summary N.J.S.A. 45:3B-8 establishes the educational requirements for licensure as an audiologist or speech-language pathologist. An applicant for licensure is required to hold a master's degree or its equivalent. Existing N.J.A.C. 13:44C-3.2 and 3.4 provide that the equivalent to a master's degree is either a doctoral degree or a bachelor's degree with an additional 42 post-baccalaureate semester hours acceptable towards a master's degree. The American Speech-Language Hearing Association (ASHA) has revised its standards so that a doctoral degree is one of the nationally recognized entry level requirements for ASHA certification as an audiologist. ASHA also requires that an applicant for ASHA certification as a speech-language pathologist hold either a master's or doctoral degree. In order to comply with the new national standards, the Director proposes to amend N.J.A.C. 13:44C-3.2 and 3.4 to remove reference to a bachelor's degree as an avenue to satisfying educational requirements for licensure. Proposed amendments to the rules also clarify that the entities that accredit master's degree programs are either ASHA's Council on Academic Accreditation in Audiology and Speech-Language Pathology or the Accreditation Council for Audiology Education of the American Academy of Audiology. N.J.S.A. 45:3B-8 requires an applicant for licensure to complete a clinical internship. Existing N.J.A.C. 13:44C-3.2 and 3.4 require an applicant who completes a master's degree or bachelor's degree to complete a clinical internship that meets the standards in N.J.A.C. 13:44C-3.5. N.J.A.C. 13:44C-3.2 and 3.4 do not address clinical internships for applicants from doctoral degree programs because entry level doctoral degree programs in audiology and speech-language pathology include a clinical internship in their curriculum. The rules do not recognize the existence of non-clinical audiology and speech-language pathology doctoral degree programs, such as those that are solely research-oriented. These programs do not include clinical internships, and graduates from such programs do not satisfy the clinical licensure requirements of N.J.S.A. 45:3B-8. In order to ensure that applicants for licensure are aware that only those doctoral degree programs that include clinical internships are recognized as qualifying for licensure, the Board is proposing new N.J.A.C. 13:44C-3.5(a) to clarify that an applicant who completed a doctoral degree program must have completed a clinical internship as part of the doctoral degree and must have completed a clinical internship program after he or she has completed his or her master's degree. The Director also proposes to amend N.J.A.C. 13:44C-3.2 and 3.4 to remove references that limit clinical internship requirements to applicants from bachelor's and master's degree programs. N.J.A.C. 13:44C-3.3 sets forth curriculum requirements for bachelor's degree and master's degree programs. As bachelor's degrees will no longer be recognized as an avenue to meet educational requirements for licensure, and the Director is confident that all master's degree programs contain the appropriate curriculum content, the Director proposes to repeal N.J.A.C. 13:44C-3.3. The Director has determined that the comment period for this notice of proposal shall be 60 days; therefore, pursuant to N.J.A.C. 1:30-3.3(a)5, this notice is excepted from the rulemaking calendar requirement. Social Impact As the proposed amendments and repeal recognize existing national standards that applicants for licensure as audiologists and speech-language pathologists are already meeting in order to take the licensing examination, the Director anticipates that the proposed amendments and repeal will have minimal, if any, social impact. The existing rule provisions permit applicants to obtain a license if they complete a bachelor's degree and 42 semester hours. Since such applicants are not [page=1963] permitted to take the licensing examination, they are not able to obtain a license regardless of whether the Board recognized the bachelor's degree in the rules and, therefore, the proposed amendments should have little impact on such applicants. When these national standards were changed, there was a positive social impact on those who would apply for licensure as audiologists and speech-language pathologists as they received additional education that better prepared them to practice in their chosen profession. Economic Impact As the proposed amendments and repeal recognize existing national standards that applicants for licensure as audiologists and speech-language pathologists are already meeting, the Director anticipates that the proposed amendments and repeal will have minimal, if any, economic impact. The existing rule provisions permit applicants to obtain a license if they complete a bachelor's degree and 42 semester hours. Since such applicants are not permitted to take the licensing examination, they had no economic incentive to complete a master's degree and it is unlikely that the proposed amendments will result in actual increased costs for applicants. When these national standards were changed, those who were interested in becoming audiologists and speech-language pathologists incurred costs in order to complete the new educational requirements imposed by ASHA in order to take the licensing examination. Federal Standards Statement A Federal standards analysis is not required because there are no Federal standards or requirements applicable to the subject matters of the proposed amendments and repeal. Jobs Impact The proposed amendments and repeal will not increase or decrease the number of jobs in New Jersey. Agriculture Industry Impact The Director does not believe that the proposed amendments and repeal will have any impact on the agriculture industry of this State. Regulatory Flexibility Statement The Regulatory Flexibility Act, N.J.S.A. 52:14B-16 et seq., requires the Director to give a description of the types and an estimate of the number of small businesses to which the proposed amendments and repeal will apply. A regulatory flexibility analysis is not required because the proposed amendments and repeal only apply to applicants for licensure who cannot be considered small businesses because they do not yet have a license to practice audiology or speech-language pathology. Housing Affordability Impact Analysis The proposed amendments and repeal will have an insignificant impact on affordable housing in New Jersey and there is an extreme unlikelihood that the rules would evoke a change in the average costs associated with housing because the proposed amendments and repeal concern educational requirements for licensure. Smart Growth Development Impact Analysis The proposed amendments and repeal will have an insignificant impact on smart growth and there is an extreme unlikelihood that the rules would evoke a change in housing production in Planning Areas 1 or 2, or within designated centers, under the State Development and Redevelopment Plan in New Jersey because the proposed amendments and repeal concern educational requirements for licensure. Full text of the rule proposed for repeal may be found in the New Jersey Administrative Code at N.J.A.C. 13:44C-3.3. Full text of the proposed amendments follows (additions indicated in boldface thus; deletions indicated in brackets [thus]): SUBCHAPTER 3. REQUIREMENTS FOR LICENSURE AS AUDIOLOGIST OR SPEECH-LANGUAGE PATHOLOGIST 13:44C-3.2 Requirements for licensure (a) An applicant for licensure shall submit to the Committee proof that the applicant has: 1. Graduated from: i. A doctoral degree program in the area of audiology, speech-language pathology, or both, accredited by either the Council on Academic Accreditation in Audiology and Speech-Language Pathology of the American Speech-Language-Hearing Association or the Accreditation Council for Audiology Education of the American Academy of Audiology. The college or university awarding the degree shall be recognized by either the New Jersey Commission on Higher Education or another state's department of education; or ii. A master's degree program in the area of audiology, speech-language pathology, or both, [at an] accredited by either the Council on Academic Accreditation in Audiology and Speech-Language Pathology of the American Speech-Language-Hearing Association or the Accreditation Council for Audiology Education of the American Academy of Audiology. The college or university awarding the degree shall be recognized by either the New Jersey Commission on Higher Education[,] or another state's department of education[, which meets the educational requirements of N.J.A.C. 13:44C-3.3]; [or] and [iii. A bachelor's degree from an accredited college or university recognized by the New Jersey Commission on Higher Education, or another state's department of education, and 42 post-baccalaureate semester hours acceptable toward a master's degree at a college or university recognized by the New Jersey Commission on Higher Education, or another state's department of education. Of these 42 hours, at least 30 shall be in the area of speech-language pathology or audiology and at least 21 shall be obtained from a single college or university. No more than six hours may be in courses that provide credit for clinical practice. The bachelor's degree and post-baccalaureate hours shall meet the educational requirements of N.J.A.C. 13:44C-3.3; and] 2. (No change.) (b) An applicant [who completed a master's degree or bachelor's degree pursuant to (a)1ii or iii above] shall also complete a clinical internship, in accordance with the provisions of N.J.A.C. 13:44C-3.5, in either audiology, speech-language pathology, or both, as appropriate. 13:44C-3.3 (Reserved) 13:44C-3.4 Licensure without examination due to licensure in another state (a) (No change.) (b) An applicant for licensure qualified pursuant to (a) above shall submit to the Committee proof that the applicant has: 1. Graduated from: i. A doctoral degree program in the area of audiology, speech-language pathology, or both, accredited by either the Council on Academic Accreditation in Audiology and Speech-Language Pathology of the American Speech-Language-Hearing Association or the Accreditation Council for Audiology Education of the American Academy of Audiology. The college or university awarding the degree shall be recognized by either the New Jersey Commission on Higher Education or another state's department of education; or ii. A master's degree program in the area of audiology, speech-language pathology, or both, [at a] accredited by either the Council on Academic Accreditation in Audiology and Speech-Language Pathology of the American Speech-Language-Hearing Association or the Accreditation Council for Audiology Education of the American Academy of Audiology. The college or university awarding the degree shall be recognized by the New Jersey Commission on Higher Education or another state's department of education; [or] and [iii. A bachelor's degree from a college or university recognized by the New Jersey Commission on Higher Education, or another state's department of education, and 42 post-baccalaureate semester hours acceptable toward a master's degree. Of these 42 post-baccalaureate hours, at least 30 shall be in the area of speech-language pathology or audiology and at least 21 shall be obtained from a single college or university. No more than six hours may be in courses that provide credit for clinical practice; and] 2. (No change.) (c) An applicant [who completed a master's degree or bachelor's degree pursuant to (b)1ii or iii above] shall also[: 1. Meet the educational requirements of N.J.A.C. 13:44C-3.3; and [page=1964] 2. Complete] complete a clinical internship, in accordance with the provisions of N.J.A.C. 13:44C-3.5, in either audiology, speech-language pathology, or both, as appropriate. 13:44C-3.5 Requirements for clinical internship (a) An applicant who completed a doctoral degree shall have completed a clinical internship that met the requirements of (b) through (h) below during the doctoral degree program. An applicant who completed a master's degree shall have completed a clinical internship that met the requirements of (b) through (h) below after he or she completed his or her master's degree program. Recodify existing (a)-(g) as (b)-(h) (No change in text.)
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